Global Code of Conduct Introduction This Study Group Code of Conduct sets out the minimum standards expected of all individuals who work within or for Study Group.This document and associated policies do not apply to our students, unless stated otherwise. These global standards provide the behavioural principles that you must adhere to within your role.You, your colleagues and your managers are expected to apply and follow these standards during your time working here, irrespective of location, business, job role or contract type (employee, casual worker, agency worker). Some sections have more detailed global policies and/or non-contractual processes, forms or supplementary information that must also be applied within your geographical region or business.Where this is the case, these are clearly identified within the relevant section.Academic policies that relate specifically to the training, supervision and protection of students within your college or school are not included in here. These will be signposted to you separately by your academic institution. This Code of Conduct will be reviewed and refreshed annually as part of our ongoing working relationship.If a standard is amended during the year, then your Human Resources team will notify you, and the most current version will continue to be linked from the regional People Policy pages of myStudyGroup.com It is imperative that you raise any concerns regarding our expectations of you at the earliest opportunity, as not abiding by the minimum standards may result in disciplinary action. Jeanette Gooding Global HR DirectorStudy Group Working for StudyGroupGlobal Code of Conduct Effective Date: 1 June 20151.0Page 2 of 26 Conflicting Information With around 3,000 employees and a huge international reach, you will find on occasion that the global principles outlined here conflict with other advice that you have been provided with. So which standard are you expected to follow? 1.Firstly, the minimum standards expected by Study Group of all individuals are outlined here, so this the Global Code of Conduct - is always your starting point. 2.Where your employment contract, regulatory requirements, or country/state legislation say that you must do something different, then it is more important that you follow the law. Always do what you are legally required to. 3.In all other cases, you should follow any local business-branded policies or procedures, as these should supplement the minimum Study Group standards and legislative requirements above.These might apply to all staff at your location or be specific to either academic or non-academic staff.Your local documentation may be branded differently. You are expected to read, understand and comply with the terms of this Code of Conduct. However this Code of Conduct does not form part of your contract of employment with Study Group and/or its subsidiaries. If you identify an inconsistency or are unclear as towhat is expected of you, thencontact the Regional Owner shown within these pages or speak to your Human Resources team. Version Control Version 1.0 Changes since Last Version Date Introduced1 June 2015 Next Review DateDecember 2015in preparation for 2016 revision Earlier Versions Working for StudyGroupGlobal Code of Conduct Effective Date: 1 June 20151.0Page 3 of 26 Contents Alcohol and Drugs ........................................................................................................................................... 4 Attendance ...................................................................................................................................................... 5 Bribery and Corruption ................................................................................................................................... 6 Bullying and Harassment ................................................................................................................................ 7 Child / Student Protection .............................................................................................................................. 8 Confidentiality ................................................................................................................................................. 9 Conflicts of Interest - Working Elsewhere .................................................................................................... 10 Corporate Social Responsibility- Positively contributing to communities and the environment ............... 11 Data Protection and Privacy ......................................................................................................................... 12 Delegation of Authority- who can authorise expenditure .......................................................................... 13 Dress Code .................................................................................................................................................... 14 Employee Concerns - Grievance, Whistleblowing ........................................................................................ 15 Employer Concerns - Misconduct, Gross Misconduct .................................................................................. 16 Equal Opportunities ...................................................................................................................................... 17 Health & Safety ............................................................................................................................................. 18 Intellectual Property- who owns the outputs that you create while working here ................................... 19 Performance Management ........................................................................................................................... 20 Personal Conduct .......................................................................................................................................... 21 Rights to Search ............................................................................................................................................ 22 Smoke Free Workplace ................................................................................................................................. 23 Social Media .................................................................................................................................................. 24 Travel and Expenses ...................................................................................................................................... 25 Use of Technology ......................................................................................................................................... 26 Working for StudyGroupGlobal Code of Conduct Effective Date: 1 June 20151.0Page 4 of 26 Alcohol and Drugs It is imperative for the health, safety and welfare of colleagues and students, and the companys professional reputation, that an individuals judgement, work performance or behaviour at work is not affected by the use of either alcohol, prescribed medication or illicit drugs. As a responsible company, Study Group will provide encouragement when appropriate to an individual who is actively addressing an underlying or long-term issue. A small amount of alcohol may be consumed during recognised social occasions where this would not cause offence to colleagues, clients or suppliers, and where individuals will not be driving or using hazardous equipment that day. Where there is cause for concern that an individual is under the influence of alcohol or drugs, they will not be permitted to remain on work premises, and may be subject to disciplinary action. Study Group may initiate either drug or alcohol screening or search an individual or an individuals personal property at work, in order to monitor compliance with this policy.Should an employee refuse to consent to drug or alcohol testing (following a request from Study Group), Study Group may initiate disciplinary action on the same basis as if an employee had tested positive for alcohol or drug use. Any individual found to be in possession or believed to be manufacturing, offering or selling illicit drugs will be immediately suspended and the appropriate authorities, e.g. the Police, notified. Individuals should disclose in confidence to Human Resources any drug-related criminal conviction or violation that occurs outside of the workplace. Global Policy No Global Policy above standard applies Global Policy OwnerN/A_____________________________________________________________________ Regional Policy OwnerHuman Resources Director Australia and New Zealand Drugs and Alcohol Policy USA and Canada Drug and Alcohol PolicyUnited Kingdom and Europe No Regional Policy Rest of World No Regional Policy Working for StudyGroupGlobal Code of Conduct Effective Date: 1 June 20151.0Page 5 of 26 Attendance Punctuality and managing attendance are essential to the efficient running and reputation of Study Group.Standard working hours differ dependent upon local legislation and your location.You may be required to attend meetings and training sessions during your contracted hours, either at your normal place of work or within a reasonable travelling distance.We provide a number of options for you to take paid and unpaid time away from work, for example annual leave, rest breaks, public duties, family friendly leave.You are expected to liaise with the relevant manager at your location to schedule and agree time away from the workplace. Study Group provides a holiday allowance that matches or exceeds the legal minimum.Leave requests cannot always be granted.Therefore, you are advised to give as much advance notice as possible, and to ensure that you have managerial approval for your proposed leave dates, prior to booking any travel arrangements. You must always take your legal minimum holiday allowance within the current holiday year. In addition, you are encouraged to use the remainder of your annual allowance before the holiday year concludes, as carry over arrangements cannot be guaranteed across all locations, other than in those situations where you have been unable to take your leave due to business requirements. On occasions where you cannot schedule time away from work, due to unexpected illness, accident or circumstance, you must telephone the relevant manager at your location - or another manager where they are unavailable - before you are due to start work.It is your responsibility to keep them informed of your progress, together with your anticipated date of return.Irrespective of whether your leave is paid or unpaid, you are expected to provide medical supporting evidence where expected or requested to do so, and for the company to maintain reasonable contact directly with you.If there is no obvious leave option available to you, the company may consider written requests for unpaid leave on a case by case basis. Where you are not bound by operational or legal requirements, you may exercise your discretion as to when you may take your rest breaks.You cannot accumulate or carry over rest breaks from one day to the next, and should not utilise them either at the start or end of your working day. If you choose to work beyond your standard hours, in order to complete a particular piece of work, this should be mutually pre-agreed with your manager.Unless you are specifically covered by a paid overtime agreement, you may agree with your manager to take the same amount of time additionally worked, as paid time off in lieu.This must occur within a short time of the additional hours being worked.Managers are generally excluded from this provision as a reflection of their seniority and autonomy in how to organise their work. Global PolicyNo Global Policy above standard applies Global Policy Owner N/A _____________________________________________________________________ Regional Policy OwnerHuman Resources Director Australia and New Zealand Conduct Policy USA and CanadaAttendance Policy United Kingdom and EuropeAbsence Policy Rest of World No Regional Policy Working for StudyGroupGlobal Code of Conduct Effective Date: 1 June 20151.0Page 6 of 26 Bribery and Corruption As an acknowledged leader in international education, Study Group recognises its long-standing ethical and regulatory responsibilities to act in accordance with applicable anti-bribery and anti- corruption laws and regulations in all our global locations in which we have a presence.Study Group is committed to a zero tolerance policy and will not tolerate any acts, attempted acts, or assistance with any form of bribery or corruption whether direct or indirect. The Anti-Bribery and Anti-Corruption Policy provides clear guidance to Study Group Representatives, and all other stakeholders with whom Study Group has a relationship, on Study Groups anti-bribery and anti-corruption values and commitment to upholding these values.The Anti-Bribery and Anti-Corruption Policy is part of Study Groups wider commitment to navigate our global business ethically, responsibly and with moral integrity. Global Policy Anti-Bribery and Anti-Corruption Policy Global Policy Owner General Counsel_____________________________________________________________________ Regional Policy OwnerManaging Director Australia and New ZealandNo Regional policy North AmericaNo Regional policy United Kingdom and EuropeNo Regional policy Rest of WorldNo Regional policy Working for StudyGroupGlobal Code of Conduct Effective Date: 1 June 20151.0Page 7 of 26 Bullying and Harassment Study Group is committed to providing a professional working environment, in which everyone is treated, and treats others, with dignity and respect.Inappropriate behaviour will not be tolerated irrespective of where it occurs, for example in the workplace, on business trips, work-related events or during social functions. You are asked to avoid creating or encouraging situations that could constitute, or might lead to a perception of offensive, unwelcome or inappropriate activity.Conduct is unacceptable if a recipient finds behaviour unwanted or offensive, causes them to feel threatened, humiliated, bullied or harassed, interferes with their performance, undermines their job security, or creates a threatening or intimidating environment. The terms bullying and harassment are commonly grouped together, but in practice are two different things. Harassment is generally unacceptable conduct which is connected to sex, sexual orientation, marital status, age, race, colour, nationality, nationality, ethnic origin, religion, belief, or disability. Bullying is offensive, intimidating, malicious or insulting behaviour involving the misuse of power that can make a person feel vulnerable, upset, humiliated, undermined or threatened.Power does not always mean the instigator is in a position of authority, but can include personal strength or the power to coerce through fear or intimidation. Bullying can take the form of physical, verbal and non-verbal conduct such as physical or psychological threats, overbearing and intimidating levels of supervision or inappropriate derogatory remarks about someone's performance.Reasonable management instructions and constructive review of an individuals performance or behaviour do not amount to bullying. We encourage anyone who experiences bullying or harassment to attempt to address it informally with the individual concerned if you feel able to do so.If that is inappropriate or dialogue does not resolve the problem, then you must report it to your Human Resources team in the first instance.You can be assured that it will be treated as a serious matter and promptly investigated. Global PolicyNo Global Policy - above standard applies Global Policy Owner N/A_____________________________________________________________________ Regional Policy OwnerHuman Resources Director Australia and New ZealandAnti-Discrimination and Harassment Anti-Bullying Policy Grievance Policy USA and CanadaDiscrimination and Harassment Policy United Kingdom and EuropeAnti-Bullying and Harassment Policy Rest of WorldNo Regional Policy Working for StudyGroupGlobal Code of Conduct Effective Date: 1 June 20151.0Page 8 of 26 Child / Student Protection As a leading for profit education provider for international students, the safeguarding and welfare of all our students is of paramount importance.We owe a higher duty of care to our students who are aged under 18.Each Region has its own policies and procedures for identifying, managing and mitigating risk of child protection issues and concerns. All staff are expected to be aware of, and fully understand, the policies and procedures for their Region and act in accordance with them at all times. All policies and procedures will reflect our commitment to; Provide a safe environment for all our students, Swiftly and efficiently identify and manage cases where students are at risk, or have unmet welfare needs, Promote the importance of child protection, safeguarding and welfare across all activities; and Regularly evaluate our approach and practices with regards to child protection, safeguarding and welfare, and make any improvements needed. Global Policy No Global Policy - above standard applies Global Policy Owner N/A _____________________________________________________________________ Regional Policy OwnerOperations Director Australia and New Zealand Child Protection Policy USA and CanadaNo Regional Policy United Kingdom and EuropeChild Protection Policy Rest of World No Regional Policy Working for StudyGroupGlobal Code of Conduct Effective Date: 1 June 20151.0Page 9 of 26 Confidentiality In the course of your work, you will receive privileged and confidential information which must not be shared with third parties other than where required by your role, either during or after your time working at Study Group, without explicit prior written permission from a senior manager at Study Group. Study Group has gone to great expense and effort to develop our extensive range of business practice and information.This includes but is not limited to documents and knowledge such as customer and contact lists, marketing plans, our methods of conducting business, submission and proposal procedures, inventions, designs, computer programs, patents, copyrights, procedures, manuals, confidential reports. The company considers and treats our information and materials as trade secrets. This includes materials that you have developed whilst working at Study Group.Trade secrets are a valuable, special and unique asset of our business, which is essential to the continued success of our schools and offices. Any improper personal use, retention, disclosure and/or transfer of confidential information or trade secrets constitutes unacceptable behaviour, even where it is not apparent that an individual has personally gained by such action.Any individual who is believed to be engaging in or has engaged in such practice will be subject to immediate and appropriate action, including termination and/or legal action. Global Policy No Global Policy - above standard applies Global Policy Owner N/A _____________________________________________________________________ Regional Policy OwnerHuman Resources Director Australia and New Zealand Conduct Policy USA and CanadaConfidentiality Policy United Kingdom and EuropeRefer to Contract of EmploymentRest of World No Regional Policy Working for StudyGroupGlobal Code of Conduct Effective Date: 1 June 20151.0Page 10 of 26 Conflicts of Interest - Working Elsewhere Study Group recognises that individuals may be engaged in work-related activities outside of your employment.You must inform your manager of any potential or actual conflicts of interest, in order that we are aware of and can manage the risks in conjunction with you. You must not supplement and/or engage in competition with Study Group activities, for example by providing additional classes to our students, without explicit prior written permission from and ongoing review by a senior manager at Study Group. Even where activities are unrelated to our business, we still retain legal obligations towards you, and you to us. It is immaterial as to whether you are acting in a paid or unpaid capacity. Global PolicyNo Global Policy - above standard applies Global Policy Owner N/A _____________________________________________________________________ Regional Policy OwnerHuman Resources Director Australia and New Zealand Conduct Policy USA and CanadaNo Regional Policy United Kingdom and EuropeRefer to Contract of Employment Rest of World No Regional Policy Working for StudyGroupGlobal Code of Conduct Effective Date: 1 June 20151.0Page 11 of 26 Corporate Social Responsibility- Positively contributing to communities and the environment Study Group prepares students for life in a global society and success in a global economy.Due to our extensive international network, we are privileged to play a pivotal role within the communities we serve.Whilst financial factors, company size, business strategy, management, brand quality, corporate image and reputation are all intrinsic elements of our success, this is balanced by our aligning corporate values with wider ethical and societal considerations. As an organisation operating in communities around the world, Study Group recognises the global disparity of educational opportunities and seeks to make a difference by funding the construction of schools in disadvantaged communities.Our vision is to provide a long-term, sustainable commitment to educational projects within developing regions through our Building Futures programme. We also aim to behave responsibly in regards to our impact on the environment, business ethics and employment practices.We can only accomplish this if consideration for these objectives is integrated into our decision making.In your role with Study Group, you may be asked to participate in key decisions, and ensure that we adhere to, or exceed, international and local minimum standards. Everyone has a part to play in managing our impact, however large or small, whether it is voluntarily contributing to Building Futures, ensuring safe working practices, sourcing ethical products or minimising the consumption of natural resources and energy. Global PolicyBuilding FuturesGlobal Policy Owner Corporate Human Resources Director_____________________________________________________________________ Regional Policy OwnerHuman Resources Director Australia and New Zealand No Regional Policy USA and CanadaNo Regional Policy United Kingdom and EuropeNo Regional Policy Rest of World No Regional PolicyWorking for StudyGroupGlobal Code of Conduct Effective Date: 1 June 20151.0Page 12 of 26 Data Protection and Privacy Personal data held by Study Group in relation to your employment is treated as confidential company information.It will be obtained and processed fairly, lawfully and confidentially stored.Records will be accurate, proportionate to the purpose that they are being used for, not held longer than necessary and may only be disclosed to third parties in appropriate circumstances, for example in order to process payroll or comply with legislation. You retain responsibility for providing Study Group with accurate and current information regarding your personal circumstances where these are relevant to the employment relationship. If you have access to records relating to colleagues, students or agents as part of your role, you must take all reasonable care to protect these from unauthorised access or disclosure. If you manage staff, your responsibilities include creating, reviewing and protecting confidential information about others. Global PolicyNo Global Policy - above standard applies Global Policy Owner N/A _____________________________________________________________________ Regional Policy OwnerHuman Resources Director Australia and New Zealand Privacy Policy and Use of Technology Policy USA and CanadaNo Regional Policy United Kingdom and Europe Data Protection Policy Rest of World No Regional Policy Working for StudyGroupGlobal Code of Conduct Effective Date: 1 June 20151.0Page 13 of 26 Delegation of Authority- who can authorise expenditure Study Group needs to protect its assets and maintain appropriate financial controls, in order to run our business effectively and ensure cohesion and consistency to our strategic direction. The company has clearly defined expectations around who can enter into binding business commitments.Authority for entering into contracts or agreements with third parties is delegated to certain functions and management roles. Individuals who are not Study Group employees, for example agency workers, consultants and contractors, are not allowed to commit any funds or approve expenditure on behalf of Study Group. Detailed guidance is provided for both managers and employees as to the levels of expenditure that are allowed, which roles can incur items of expenditure, and who can approve expenditure.Employees must not make any oral or written commitments with a third party, without the required level of approval. Those individuals who have authority to approve expenditure are expected to exercise good business judgment.Approval must be in line with Study Groups strategies, procedures and budgets.Individuals may only approve expenditure within their function, area of expertise or cost centre. There must always be appropriate supporting documentation before any commitment is entered into, and records maintained.Your finance team will only process transactions that comply with the terms outlined within the relevant policy. Global Policy Matters Reserved for the Board Delegation of Authority Corporate Policy Global Policy OwnerChief Financial Officer_____________________________________________________________________ Regional Policy OwnerFinance Director Australia and New Zealand Delegation of Authority Divisional Policy North AmericaDelegation of Authority Divisional Policy United Kingdom and EuropeDelegation of Authority Divisional Policy Rest of World Delegation of Authority Divisional Policy Working for StudyGroupGlobal Code of Conduct Effective Date: 1 June 20151.0Page 14 of 26 Dress Code It is important to Study Group that the professionalism and trust placed in our staff and colleagues is always held in high regard by others.Gaining respect is highly influenced by both non-verbal cues and what we say. Our appearance and how we present ourselves is important, as this can build, or undermine, the perception of you and of us as an organisation. Not all of us directly interact with students.However, it is still important that both academics and non-academic colleagues create a positive impression, and that we mirror the expectations that will be placed on our students when they progress into the working environment.If you are provided with a uniform, you are expected to wear this and to keep it clean. As we work alongside younger people, we are not mandating that staff should be dressed formally.Nor would it always be appropriate.For instance, if you are an activities organiser, then you are not going to be dressed in the same way as a sales agent. Whatever you wear, we ask that you always maintain a tidy appearance, and to respect the following guidelines: No sports or beach wear, unless appropriate to your role No humorous/political/advertising logos All non-ear piercings to be covered up during work hours No clothing that is too revealing, suggestive or tight fitting Global Policy No Global Policy - above standard applies Global Policy OwnerN/A _______________________________________________________________________ Regional Policy OwnerHuman Resources Director Australia and New Zealand Dress Code Policy USA and CanadaDress Code Policy United Kingdom and EuropeNo Regional Policy Rest of World No Regional Policy Working for StudyGroupGlobal Code of Conduct Effective Date: 1 June 20151.0Page 15 of 26 Employee Concerns - Grievance, Whistleblowing Our aim is to provide a positive and productive working environment in which constructive dialogue and suggestions are welcomed and support always given.We realise however that there might be occasions when you, your manager or a colleague become dissatisfied with a particular course of action, and you require a structured and safe mechanism for dealing with these concerns, without fear of reprisal for doing so. Do not hesitate to raise genuine concerns, even if later these are determined to be unfounded.We always encourage you to attempt resolution informally first, by engaging in dialogue either with the individual concerned or your manager.Where this is inappropriate or does not resolve an issue, then the company provides structured procedures for you to follow. The company will engage with you, and resolve matters at what it considers to be the most appropriate level and as promptly and consistently as business constraints allow. Where, following due consideration, it is decided that the concerns were raised maliciously or that the complaints are frivolous or vexatious, the relevant employee may be subject to disciplinary action, up to and including termination of employment. Global Policy No Global Policy - above standard applies Global Policy OwnerN/A _____________________________________________________________________ Regional Policy OwnerHuman Resources Director Australia and New Zealand Grievance Policy USA and CanadaWhistle-blowing Policy United Kingdom and EuropeUK and Rest of World Grievance Process and Whistleblowing Process Rest of World UK and Rest of World Grievance Process and Whistleblowing Process Working for StudyGroupGlobal Code of Conduct Effective Date: 1 June 20151.0Page 16 of 26 Employer Concerns - Misconduct, Gross Misconduct We hope that our employment relationship will be mutually beneficial.However, we recognise that there may be occasions when you do not follow the contractual or behavioural standards that are expected of you.If this occurs, then it is important that we follow a structured and fair process for warning you that your conduct is not acceptable, and that the employment relationship is in jeopardy. Firstly, we provide you with the standards that are expected of you, beginning with this Global Code of Conduct.Where principles are not adhered to or misconduct occurs, this is treated and resolved by the company applying the disciplinary process. Whilst not an exhaustive nor exclusive list, examples of unacceptable behaviour known as misconduct - that may result in a warning include: unauthorised absence from work failure to wear appropriate protective clothing or uniform where supplied poor timekeeping breach of a reasonable company or management instruction improper use of equipmentunprofessional behaviour when talking to or working with colleagues or students behaviour inconsistent with your duty to loyally and properly carry out your role MoreseriousbreachesareknownasGrossMisconductandcouldresultindisciplinaryactionresultingin termination of your employment.Examples include but are not limited to: any action or behaviour which is likely to damage the reputation of the company theft, fraud or dishonesty (including providing false or misleading information) fighting or assaultconsumption or dealing in drugscausing financial loss to the company serious breaches of company standards knowingly putting others health and safety at risk disclosing confidential informationGlobal Policy No Global Policy - above standard applies Global Policy OwnerN/A_____________________________________________________________________ Regional Policy OwnerHuman Resources Director Australia and New Zealand Conduct Policy USA and CanadaCorrective Discipline Policy United Kingdom and EuropeUK and Rest of World Disciplinary Process Rest of World UK and Rest of World Disciplinary Process Working for StudyGroupGlobal Code of Conduct Effective Date: 1 June 20151.0Page 17 of 26 Equal Opportunities Study Group promotes equal opportunity and the avoidance of discrimination, by treating individuals equally and with fairness at all times when making employment decisions. We want you to be able to fulfil your potential and build positive working relationships within a flourishing and dynamic environment, in which your views are welcomed and the diversity of our staff and student communities are a cause for celebration. We will achieve this by always making objective decisions based on merit, through ensuring that any unjustified barriers are removed, and by monitoring our progress. We are committed to seeking continual improvement, in line with compliance to local legislation, in order to prevent discrimination in the workplace.All of us hold a responsibility, irrespective of our role, to ensure that we adopt fair, inclusive and consistent practices throughout the organisation, and to report any deviation from this. With your help, we can remove disadvantages where these apply, so that you can fully play your part within our vibrant organisation.It does not matter to us how old you are, whether you have a physical or mental disability, are single, married, with a partner, part-time, full-time, what your gender is, whether you have parental responsibility, what nationality, religion, or sexual orientation you are.What you positively contribute and how you perform your role on a daily basis are what matter to us. In order to ensure that everyone can fully maximise their contribution, let Human Resources and/or your manager know if you need support, or we should be made aware of something that is important to you. Global Policy No Global Policy - above standard applies Global Policy OwnerN/A ________________________________________________________________________ Regional Policy OwnerHuman Resources Director Australia and New Zealand Equal Employment Opportunity Policy USA and CanadaEqual Employment Opportunity Policy United Kingdom and EuropeEquality and Diversity PolicyRest of World No Regional Policy Working for StudyGroupGlobal Code of Conduct Effective Date: 1 June 20151.0Page 18 of 26 Health & Safety Study Group will strive to provide, so far as is reasonably practicable, a safe and healthy working and studying environment for all employees, students and others including those at special risk, according to its responsibilities under local legislation from time to time. It is Study Group's policy to take all reasonable steps to: Provide and maintain safe and healthy working and studying conditions. Provide safe plant/equipment and safe systems of work for all employees and, where applicable, students Ensurethecompetenceofallemployeestodotheirworkandprovide relevant information, instruction and supervision for all employees and, where applicable, students Adequately control health and safety risks arising from work activities Collect and disseminate up-to-date relevant information on health and safety matters. Protectthehealthandsafetyofotherswhomightbeaffectedbywork activities including students, visitors, contractors and members of the public. Global Policy No Global Policy - above standard applies Global Policy OwnerN/A_____________________________________________________________________ Regional Policy OwnerNamed individual per region / Operations Director Australia and New Zealand Health, Safety & Wellbeing USA and CanadaHealth & Safety Policy United Kingdom and EuropeUK Health & Safety Huddle Rest of World No Regional Policy Working for StudyGroupGlobal Code of Conduct Effective Date: 1 June 20151.0Page 19 of 26 Intellectual Property- who owns the outputs that you create while working here Your appointment is intrinsically linked to the skills, knowledge, experience and capabilities that you can bring to the organisation, and hence the value that you can provide and add within your role. You have a special duty to further Study Groups interests in this regard. Therefore, anything that you design or develop within the course of your employment becomes and remains the property of Study Group and/or its subsidiaries. Global PolicyNo Global Policy - above standard applies Global Policy OwnerN/A _____________________________________________________________________ Regional Policy OwnerHuman Resources Director Australia and New Zealand No Regional Policy USA and CanadaNo Regional Policy United Kingdom and EuropeRefer to Contract of EmploymentRest of World No Regional Policy Working for StudyGroupGlobal Code of Conduct Effective Date: 1 June 20151.0Page 20 of 26 Performance Management Study Group is committed to fostering a work environment that maximises individual and business performance.In order to achieve this, it is important that you are clear as to our performance and behavioural expectations, you understand where your role and contribution fit into the wider organisational and team goals, you work towards clear objectives, and you participate in the regular receiving and giving of feedback and developmental support. When you first work with us, there is an initial settling in period, during which both you and we assess whether we are mutually suited and compatible.We will help you understand what is expected from you in your particular role, set some preliminary goals and encourage two way dialogue. Irrespective of whether you have just joined or have been here many years, everyone should receive regular, honest feedback on what they are doing and how they are doing it.A formal performance appraisal is completed every twelve months, in order to ensure that there is a structured review of personal reflection and growth, before mutually agreeing the next set of goals, and identifying any individual or collective training requirements. These factors apply just as equally to your manager too.You should feel comfortable in asking for support or suggesting what they can do differently, in order to increase your levels of job satisfaction and performance. Global PolicyNo Global Policy - above standard applies Global Policy OwnerN/A _____________________________________________________________________ Regional OwnerHuman Resources Director Australia and New Zealand Corrective Performance Management USA and CanadaPerformance Management United Kingdom and EuropeNo Regional PolicyRest of World No Regional Policy Working for StudyGroupGlobal Code of Conduct Effective Date: 1 June 20151.0Page 21 of 26 Personal ConductWorkspace Management A kitchen is provided for the use of the staff. In the interests of everyone's health and safety and a pleasant working environment you are required to keep this, and your general work area, clean and tidy.Before leaving for the evening, make sure your desktop is clear of documents, dirty crockery, and generally left in a tidy state.This allows the cleaning staff to clean your desk, ensures that confidential items have been safely secured, lessens the chance of losing or misplacing work, and enables others to work at your desk if you are away. Please put all litter and recyclable materials into the appropriate bins and ensure any confidential waste is disposed of securely. Music As much of our business takes place over the telephone and in shared office spaces, we ask that you refrain from playing music or radios in the workplace, other than where required for teaching purposes.As persistent music and unnecessary commentary can be distracting and disturbing to others even at low volume, personal headsets and all personal music devices should not be used during working hours, without permission from your manager.

Personal Property Most of our facilities have public access and we often have open plan offices and workspaces.We advise you not to bring valuable personal possessions or large amounts of cash to work, as you do so at your own risk. You are responsible for the security of your personal possessions, and we cannot take responsibility for the replacement of lost or stolen personal property. Working Together A sense of teamwork and camaraderie are key ingredients to helping Study Group to succeed, and for you to enjoy working here. Swearing within the working environment is unacceptable.If you have a disagreement with other individual(s), then Study Group expects a professional approach to be adopted. Any direct or indirect act or threat of verbal or physical violence against any member of staff, customer or another person at work is likely to result in disciplinary action up to and including dismissal, and could result in criminal prosecution. Relations with the local community Study Group believes in maintaining good relations with the local community and you are requested to comply with this, for example by handling any queries from the general public quickly and courteously; treating the companys neighbours and their property with respect; not parking your car to cause obstruction or nuisance near work; not throwing litter in the street or in the vicinity of the companys premises; not smoking in front of other organisations or private individuals doors; and, leaving work quietly, particularly after normal working hours. Global PolicyNo Global Policy - above standard applies Global Policy OwnerN/A _____________________________________________________________________ Regional Policy OwnerHuman Resources Director Australia and New Zealand Business Conduct USA and CanadaNo Regional Policy United Kingdom and EuropeNo Regional Policy Rest of World No Regional Policy Working for StudyGroupGlobal Code of Conduct Effective Date: 1 June 20151.0Page 22 of 26 Rights to Search A key factor in the relationship between you and Study Group depends upon a high degree of mutual trust and confidence.We collectively rely on each other to be honest and respectful and not to conduct ourselves in a manner calculated to destroy this fundamental principle.We expect you to serve Study Group loyally and in good faith by not: misusing company property or resources soliciting customers or clientssetting up in direct competition with usdisrupting our businessdamaging our company reputation risking the health and safety of students or colleagues We monitor what happens in our business via a variety of methods such as reviewing the usage of IT equipment and communications, CCTV recording, implementing security measures, etc. to ensure that our business and the personal interests of your colleagues and students are protected. By working here, you accept that if there is justifiable cause, then Study Group may use appropriate search methods.Other than for routine searches, if there is justifiable concern regarding your behaviour, then a physical search of you/r personal effects may be conducted in line with the following principles: Yourconsentwouldberequested,andthereasonforthesearchexplained(unless you are non-contactable and it is felt that the search of your personal effects cannot wait until your anticipated return, in which case you will be informed that a search has taken place at the earliest opportunity)The search would be conducted by a member of security or a managerAn available, mutually-acceptable witness should be present The search would be carried out with care and respect for your belongings Physical contact would be minimised and carried out by a member of the same sex The search will be conducted as privately as possible in the circumstances The results will be confidentially loggedThe results will only be shared by you and us on a need to know basis Should you refuse a search request, then you should state precisely why you are refusing, as Study Group will draw its own conclusion from your refusal.Study Group always reserves the right to call in an appropriate external authority such as the Police where there is suspicion of, or a matter is considered to be, unlawful. Global PolicyNo Global Policy - above standard applies Global Policy OwnerN/A _____________________________________________________________________ Regional Policy OwnerHuman Resources Director Australia and New Zealand No Regional Policy USA and CanadaNo Regional Policy United Kingdom and EuropeNo Regional Policy Rest of World No Regional Policy Working for StudyGroupGlobal Code of Conduct Effective Date: 1 June 20151.0Page 23 of 26 Smoke Free Workplace Study Group operates a smoke-free environment.This includes but is not limited to all reception areas, offices, staff rooms and restaurants, and applies equally to electronic cigarettes, otherwise known as e-cigarettes. You may however smoke in the designated smoking area for your location. We do not provide additional breaks for individuals who smoke.Therefore, you should endeavour to smoke during designated rest breaks.If you smoke outside of a designated rest break with the acceptance of your manager, you must not exceed your maximum daily break allowance, so for example you would need to reduce your lunch break accordingly. Global PolicyNo Global Policy - above standard applies Global Policy OwnerN/A _____________________________________________________________________ Regional Policy OwnerHuman Resources Director Australia and New Zealand No Regional Policy USA and CanadaNo Regional Policy United Kingdom and EuropeNo Regional Policy Rest of World No Regional Policy Working for StudyGroupGlobal Code of Conduct Effective Date: 1 June 20151.0Page 24 of 26 Social Media Social media is the social interaction in which individuals create, share or exchange information, ideas, and pictures or videos within virtual communities and networks.This includes all forms of social media, including Facebook, LinkedIn, Twitter, Google+, Wikipedia, Whisper, Instagram, Vine, Tumblr and all other social networking sites, internet postings and blogs.It applies to use of social media for business purposes as well as personal use that may affect our business in any way. We encourage use of social media where it is used appropriately, such as building your professional profile, contributing to positive engagement with colleagues, and following our organisational posts. You are permitted to add limited business contacts to your personal social networking accounts, on the strict condition that you or a third party do not use or share this information to compete with Study Group either now or in the future, or to solicit our contacts.From a child and student protection perspective, you must not socially connect with current students, unless you have authorisation to do so through channels that specifically exist and are permitted within your business.Generally, social media is permitted provided such use is lawful, does not occur when you are working - unless it is a fundamental requirement of your role, does not negatively impact upon you or others performance, or damage the reputation, image, performance, security or availability of Study Group or its IT systems. The use of social media must not cause any additional cost to Study Group. You must avoid making any social media or media communications that could directly or indirectly damage our business interests or reputation.You must not use social media to defame or criticise us, our staff or any third party; to harass, bully or unlawfully discriminate against individuals or organisations; to make false or misleading statements; or to impersonate colleagues or third parties.You must not express opinions on our behalf via social media, unless expressly authorised to do so. Nor must you post comments about sensitive business-related topics, such as our performance, or do anything to jeopardise our trade secrets, confidential information or intellectual property.You must not include our logos or other trademarks in any social media posting or in your profile. You may not set up social media profiles or pages on behalf of, or designed to represent, the company, unless authorised by your Regional Owner. You should make it clear in postings, or in your personal profile, that you are speaking on your own behalf.Always write in the first person and use a personal email address.Be respectful to others when making any statement and be aware that you are personally responsible for any harm caused. If you disclose your link with us on your profile or in postings, you must state that your views do not represent those of Study Group, unless you are authorised to speak on our behalf.You should also ensure that your profile and any content you post are consistent with the professional image we would wish to present to clients and colleagues.If you are uncertain or concerned about the appropriateness of any statement or posting, refrain from posting it until it has been approved.You may be required to remove any social media content that we consider to be inappropriate.Global PolicyNo Global Policy - above standard applies Global Policy OwnerSocial Media Manager, UK & Europe _____________________________________________________________________ Regional OwnerMarketing Team (Australia & New Zealand, USA & Canada) Social Media Manager (UK & Europe, Rest of World) Australia and New Zealand Social Media Policy USA and CanadaNo Regional Policy United Kingdom and EuropeNo Regional Policy Rest of World No Regional Policy Working for StudyGroupGlobal Code of Conduct Effective Date: 1 June 20151.0Page 25 of 26 Travel and ExpensesExpenses, travel and associated expenditure represent a significant cost to the organisation.It is important therefore that you have a clear and consistent understanding of which expenses are reimbursed and how and when to claim them. Detailed guidance is provided, in order that you can familiarise yourself with what is acceptable expenditure and the expense procedures that you must follow.The policy covers a diverse range of topics including international and domestic travel, meals and entertainment, off-site meetings, communication costs, professional membership fees and subscriptions, special personal occasions (e.g. retirement), company social events, charitable donations, and treatment of rewards and recognition.It also provides you with which expenses are not reimbursable, for example non-employee expenses or when to contact Human Resources on employment related matters such as taxation incurred by your employment in another country, relocation expenses or remote working. Expenses must always be legitimate and business-related, cost effective, and compliant with local tax requirements.They must be approved by a manager, who is responsible for ensuring internal compliance, and for verifying the legitimacy and accuracy of charges.Overstating incurred expenditure or making false claims will be viewed seriously as an attempt to defraud the company.By approving an expense, the approving manager will be held accountable, in the same way as the individual who submitted the fraudulent expense claim. Expense reports will be subject to audit. Where a genuine error has occurred, individuals will be required to repay any monies incorrectly reimbursed to them. Global PolicyGlobal Travel and Expenses Policy Global Policy OwnerChief Financial Officer_____________________________________________________________________ Regional Policy OwnerFinance Director Australia and New Zealand Any additional information may be found in the Australia andNew Zealand pages North AmericaNo Regional PolicyUnited Kingdom and EuropeNo Regional PolicyRest of World Any additional information may be found in the Rest of World pages Working for StudyGroupGlobal Code of Conduct Effective Date: 1 June 20151.0Page 26 of 26 Use of TechnologyYou are expected to adhere to the separate, more detailed global policy, which deals with the provision of technology resources by Study Group and the associated responsibility of authorised users when accessing Study Group business tools and information. These resources include, but are not limited to, the Study Group network, computer systems and software, access to the Internet, electronic mail, telephony and related services.The policy is based on the following mandatory principles: The technology resources of Study Group are provided to support the teaching, research, administrative, marketing and other business activities of Study Group Authorised users are granted access to valuable Study Group resources, sensitive data and to external networks on the basis that their use of IT resources shall be responsible, ethical and lawful at all times Authorised users are required to observe Study Group policy, and all related local laws which may apply Data and information relating to persons (specifically, but not limited to potential, future, current or past students, staff or agents) and other confidential matters acquired for business purposes shall be protected Personally identifiable information shall be handled in accordance with all applicable privacy legislation and/or principles Study Group business information shall be protected from unauthorised and/or accidental disclosure; and Study Group technology resources must not under any circumstances be used to harass, humiliate or intimidate others or to offend or vilify others on the basis of their race, gender, or any other attribute prescribed under anti-discrimination legislation. Shouldyoubeawayfromwork,yourmanagerhastherighttorequestandreceiveaccesstoyour business email account and documents. Global PolicyUse of Technology Policy Global Policy OwnerGlobal IT Operations Director _____________________________________________________________________ Regional Policy OwnerIT Director Australia and New Zealand Use of Technology USA and CanadaUse of Technology Policy United Kingdom and EuropeIT Acceptable UseRest of World No Regional Policy End